§923

Tina E. Aginaga a.k.a. Tina E. Aginaga-Dove, Petitioners T.C. Memo. 2012-194 · 2012

923(g)(1)(A) (2012) (requiring firearms dealers to maintain records offirearms sales ). Respondent introduced no such evidence. Respondent misplaces re iance on petitioners' inability to substantiate the expenses claimed on their returis to prove fraud." The Court ofAppeals for the "Although we seriously question whetherthese charitable contri

Jeffrey L. & Arleen L. Kesselring, Petitioner T.C. Memo. 2012-194 · 2012

923(g)(1)(A) (2012) (requiring firearms dealers to maintain records offirearms sales ). Respondent introduced no such evidence. Respondent misplaces re iance on petitioners' inability to substantiate the expenses claimed on their returis to prove fraud." The Court ofAppeals for the "Although we seriously question whetherthese charitable contri

American Air Liquide, Inc. and Subsidiaries, Petitioner 116 T.C. No. 3 · 2001

ly with respect to each of the following items of income: (A) passive income, (B) high withholding tax interest, (C) financial services income, (D) shipping income, (E) in the case of a corporation, dividends from each noncontrolled section 902 corporation, (F) dividends from a DISC or former DISC (as defined in section 992(a)) to the extent such dividends are treated as income from sources without the United States, (G) taxable income attributed to foreign trade income (within the meaning of se

American Air Liquide, Inc. & Subsidiaries v. Commissioner 116 T.C. 23 · 2001

shipping income, (E) in the case of a corporation, dividends from each noncontrolled section 902 corporation, (F) dividends from a DISC or former DISC (as defined in section 992(a)) to the extent such dividends are treated as income from sources without the United States, (G) taxable income attributed to foreign trade income (within the meaning of section 923(b)), (H) [certain] distributions from a FSC * * *, and (I) income other than income described in any of the preceding subparagraphs.

Union Carbide Corporation & Subsidiaries, Petitioner 110 T.C. No. 28 · 1998

The FSC recognizes the nonexempt portion of its taxable income as income effectively connected with the conduct of a U.S. trade or business. Sec. 921(d). Section 925(a) provides in pertinent part: SEC. 925 (a). In General.--In the case of a sale of export property to a FSC by a person described in section 482, the taxable income of suc

Union Carbide Corp. v. Commissioner 110 T.C. 375 · 1998

The FSC recognizes the nonexempt portion of its taxable income as income effectively connected with the conduct of a U.S. trade or business. Sec. 921(d). Section 925(a) provides in pertinent part: SEC. 925 (a). In General. — In the case of a sale of export property to a FSC by a person described in section 482, the taxable income of su

General Dynamics Corporation and Subsidiaries, Petitioner 108 T.C. No. 9 · 1997

The amount of the deferral or exemption is in 5 Secs. 921-927. - 16 - controversy here. For purposes of this case, the DISC and FSC provisions are generally similar, and the parties do not argue that the outcome should vary depending on which of the provisions apply. The focus here is whether petitioners must consider period costs att

General Dynamics Corp. & Subsidiaries v. Commissioner 108 T.C. 107 · 1997

The amount of the deferral or exemption is in controversy here. For purposes of this case, the Disc and FSC provisions are generally similar, and the parties do not argue that the outcome should vary depending on which of the provisions apply. The focus here is whether petitioners must consider period costs attributable to the gross re

Broughman v. Carver 624 F.3d 670 · Cir.

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Gazzola v. Hochul 88 F.4th 186 · Cir.

Celia Mazzei, Petitioner · 2018

Angelo L. Mazzei & Mary E. Mazzei, Petitioners · 2018

American Arms International v. Herbert 563 F.3d 78 · Cir.

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Aposhian v. Barr 958 F.3d 969 · Cir.

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Gun Owners of America, Inc. v. Merrick B. Garland 19 F.4th 890 · Cir.

United States v. Timothy Harris 720 F.3d 499 · Cir.

VanDerStok v. Garland 86 F.4th 179 · Cir.

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